The new resolution will take effect on 4 August 2025, replacing the 2016 and 2017 resolutions.

Costa Rica’s Tax Administration (DGT) has published Resolution MH-DGT-RES-0026-2025 in the Official Gazette on 24 July 2025, which pertains to the submission of the transfer pricing informative statement, which was first introduced in 2016 but suspended indefinitely in 2017.

Key changes introduced by the Resolution:

  • It continues to mandate the submission of a transfer pricing informative statement for certain taxpayers.
  • It applies to large national taxpayers, entities in free zones with related-party transactions, and those with related-party dealings exceeding 1,000 base salaries annually.
  • For 2025, the threshold is set at CRC 462,200,000, based on a base salary of CRC 462,200.
  • The informative statement form covers related companies, tangible and intangible asset transactions, financial operations, and other services.
  • The new resolution requires the transfer pricing informative statement to be submitted electronically via the TRIBU-CR System.
  • Submissions must follow the required format; otherwise, they will not be accepted. Failure to comply, whether fully or partially, may result in penalties under the Tax Code.

While the usual deadline for submitting a transfer filing statement is six months after year-end, the deadline for 2024 has been set for 30 November 2025.

The new resolution takes effect on 4 August 2025, and repeals the previous 2016 and 2017 resolutions.